ACOGEMA

November 14, 2008

Attn: Charles Garlow, Attorney-AdvisorOECA, Air Enforcement DivisionU.S. Environmental Protection Agency1200Pennsylvania Ave, N.W. - MC 2242AWashington, DC 20460

Dear Mr. Garlow:

Enclosed please find our response to the Request to Provide Inform~.tionPursuant to theClean Air Act as discussed in the EPA letter to COGEMAMining, ]nc. dated September2, 2008, signed by Adam Kushner, Director Air Enforcement Divisi)n. This is thesecond submittal in response to the request for information. The ini :ialresponse,submitted on October 8, 2008, addressedthe first three questions of Appendix B to thereferenced EPA letter. This submittal addresses questions 4 througll 6 of Appendix B.

Included under this cover letter is a narrative which addresses each Iluestion, a CD whichcontains various pdf files of supporting documentation that is refererlcedin the narrative,a guide which correlates the different referenced documents in the 11arrativewith thecorrect pdf files, and a certification signed by the General Manager for COGEMAMining, Inc. and Pathfinder Mines Corporation, Mr. Bernard Bonifi.s. If you have anyquestions regarding the submitted information, do'not hesitate to coItact me.

Sincerely,

r~Tom HardgroveManager, Environmental and Regulatory Affairs

Encls.

Cc: Andrew M. Gaydosh, U.S. EPA Region 8T. Pennington, AREVA NC (w/o CDs)B. Bonifas (w/o CDs)

COGEMA Mining, Inc.

935 Pendell Blvd., P.O. Box 730, Mills, WY 82644 - Tel. : (307) 234-5019 - Fax: (307) 473-7306

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CERTIFICATION STATEMENT

Concerning the Appendix B Responses (responses to questions 4 through 6) submitted toEPA on November 14, 2008,

I certify under penalty of law that I have examined and am familiar with the informationin the enclosed documents, including all attachments. Based on my inquiry of thoseindividuals with primary responsibility for obtaining the information, I certify that thestatements and information are, to the best of my knowledge and belief, true andcomplete. I am aware that there are significant penalties for knowingly submitting falsestatements and information, including the possibility of fines or imprisonment pursuant tosection 113(c)(2) of the Act, and 18U.S.C. §§ 1001and 1341.

1!IJVuJ.u I~~~Date

COGEMA Mining, Inc. & Pathfmder Mines Corp.Appendix B Response to EPA Inquiry Dated September 2, 2008.Second Phase (Questions 4-6) Responses Submitted to EPA November 14,2008

Prepared by T. Hardgrove, Manager, Environmental and Regulatory Affairs

4. Additional information on each pond identified in response to request 3.d):

a) None of the identified impoundments in 3.d utilized the continuousdisposal method. The ponds containing solid tailings at both ofPathfinder's sites (Lucky Mc and Shirley Basin) were all constructedbefore December 15, 1989as specified in 40 CFR 61, § 61.252(b). All ofthe ponds identified for COGEMA Mining, Inc. sites in 3.d are or weresolution only storage/evaporationponds containing no tailings.

b) Not applicable. As noted in 4.a, none of the ponds utilized the continuousdisposal method for solid tailings.

c) Disposal Records:Conventional Uranium Mill and Tailings Facilities -Pathfinder Mines Corp. Lucky Mc Mine: The tailings ponds atthis site pre-date the effective date of 40 CFR §61.252relative towork practices. Tailings were deposited by discharging a tailingsslurry, forming typical beaches and allowing most of the liquidportion ofthe slurry to flow to the central pool of a tailings pond.Specific disposal records are not readily available (if they exist atall). Such disposalhas not occurred at this site for over twentyyears. The method of coveringtailings is recounted in the tailingsreclamation completionreport included as a pdf file on a CDincluded with this submittal. The cleanup of contaminated soils inareas adjacent to the tailings is presented in the Lucky Mc Mill SiteCompletion Report, February, 1998,also included on the CD.

Pathfinder Mines Corp. Shirley Basin Mine: The tailings ponds atthis site pre-date the effective date of 40 CFR §61.252relative towork practices. Tailings were deposited by discharging a tailingsslurry, forming typical beaches and allowing most of the liquidportion of the slurry to flow to the central pool of a tailings pond.Specific disposal records are not readily available (if they exist atall). Such disposalhas not occurred at this site for over sixteenyears. The tailings were covered on an interim basis beforeplacement of the fmal radon barrier cover. A post-decommissioning/reclamationreport has yet to be prepared for thissite, but the covering process was done as specified in the ShirleyBasin Tailings Reclamationplan, included with this submittal as apdffile on a CD. The cleanup of wind dispersed tailings-contaminated soils in areas adjacent to the tailings is presented in

COGEMA Mining, Inc. & Pathfmder Mines Corp. Appendix B Response to EPA Inquiry Dated September2,2008. SubmittedNovember 14,2008.

the Shirley Basin Mill Site Completion Report for Reclamation ofOff-Pile Windblown Area, October, 1999, included on a CD.

In-situ Leaching Facilities -COGEMA Mining, Inc., Irigaray Mine and Christensen RanchSatelliteFacility:Notapplicable- therearenotailings.

COGEMAMining, Inc. Holiday-El Mesquite, O'Hern, and WestColeFacilities:Not applicable- there are no tailings.

d) Emissions data: See response to item 6 below.

e) Compliance with 10acres maximum uncovered at anyone time, asspecified in 40 CFR Section 6l.252(b )(2): As noted in 4.a above, all ofPathfinder's solid tailings ponds were constructedprior to December 15,1989, and were not subject to the requirements of 40 CFR Section61.252(b). Because all COGEMA Mining, Inc. ponds are solution onlythe work practices of 40 CFR 252(b) do not apply.

t) Proof of compliancewith 40 CFR § 192.32(a):Conventional Uranium Mill and Tailings Facilities -Pathfinder Mines Corp. Lucky Mc Mine:1. Ponds construction [§ 192.32(a)(1)]: All tailings ponds at thesite pre-date the effective date (December6, 1983)of 40 CFR §192.32(a).2. Conformanceto the ground water protection standard[§192.32(a)(2)]: Included with this submittal as pdffiles copied toa CD are NRC Source Material License SUA-672which containslicense condition 60 that incorporates alternate concentration limitsfor the site, a copy of the application for alternate concentrationlimits, and the NRC staff environmentalassessment prepared insupport of the alternate concentration limits approval.3. Placement of a permanent radon barrier [§192.32(a)(3)]:Included with this submittal as pdf files copied to a CD are thereclamation (closure) plan for the Lucky Mc tailings site, thelicense approvals ofthe reclamationplan, the NRC staffenvironmental assessment and technical evaluation accompanyingthe plan approvals, the tailings reclamation completion report (twovolumes), and the NRC approval of the completionreport aslicense amendment number 69.4. Monitoringof radon releases through the permanent radonbarrier [§192.32(a)(4)]: See the tailings reclamation completionreport, volumes 1 and 2, for discussion, data, and laboratoryreports relating to the post-construction radon barrier flux testingresults.5. Management of uranium byproduct materials in conformancewith Part 190 and Part 440 of 40 CFR Chapter 1[§192.32(a)(5)]:

2

COGEMA Mining, Inc. & Pathfmder Mines Corp. Appendix B Responseto EPA Inquiry Dated September2,2008. SubmittedNovember 14,2008.

Included with this submittal as pdf files copied to a CD are thedose to the public evaluations done prior to closure. Suchevaluations were not continued during the closure period. Therewere no liquid effluent dischargesrelating to the tailings site.

Pathfinder Mines Corp. Shirley Basin Mine:1. Ponds construction [§ 192.32(a)(1)]: All tailings ponds at thesite pre-date the effective date (December 6, 1983) of 40 CFR §192.32(a).2. Conformance to the ground water protection standard[§192.32(a)(2)]: Included with this submittal as pdffiles copied toa CD are NRC Source Material License SUA-442 whichcontains license condition 47 that incorporates alternateconcentration limits for the site, a copy of the application foralternate concentration limits, and the NRC staff technicalevaluation report prepared in support of the approved alternateconcentration limits.3. Placement of a permanent radon barrier [§192.32(a)(3)]:Included with this submittal as pdf files copied to a CD are thereclamation (closure) plan for the Shirley Basin Mine tailings site,the license approval of the reclamationplan, and the NRC stafftechnical evaluation accompanyingthe plan approval. All closureplan construction relating to the Shirley Basin tailings (directly onthe tailings) has been completed with the exception of Pond 3which is still being utilized for NRC authorized disposal of 11e.(2)byproduct material from certain ISL operations. Because someperipheral (off tailings) channel features have not been completedas of this submittal an interim tailings reclamation completionreport has not been submittedto the NRC. Submittal of an interimcompletion report (covering all tailings/mill site areas exclusive ofPond 3) is anticipated late in 2009.4. Monitoring of radon releases through the permanent radonbarrier [§192.32(a)(4)]: Included with this submittal as apdffilecopied to a CD is a summaryof the radon flux test resultsconducted on the final radon barrier completed to date. Alsoincluded are pdffiles of the laboratoryradon flux test data, and amap illustrating the sampling grid for the radon flux testsconducted to date on the final clay radon barrier.5. Management of uranium byproduct materials in conformancewith Part 190 and Part 440 of 40 CFR Chapter 1[§192.32(a)(S)]:Included with this submittal as pdf files copied to a CD are thedose to the public evaluationsdone prior to closure. Suchevaluations were not continued during the closure period. Therewere no liquid effluent dischargesrelating to the tailings site.

3

COGEMA Mining, Inc. & Pathfmder Mines Corp. Appendix B Response to EPA Inquiry Dated September2,2008. Submitted November 14,2008.

In-situ Leaching Facilities -COGEMA Mining, Inc., Irigaray Mine:1. Ponds construction [§ 192.32(a)(1)]: All ponds at thesite pre-date the effective date (December 6, 1983) of 40 CFR §192.32(a).2. Conformanceto the ground water protection standard[§192.32(a)(2)]: Included with this submittal as pdffiles copied toa CD are NRC Source Material License SUA-1341whichestablishes operational conditions regarding ground waterprotection, the wellfield restoration report dated July, 2004, and thesubsequent ground water restoration approvals by the WyomingDepartment of Environmental Quality (WDEQ) and the NRC.Both the WDEQ and NRC have accepted ground water restorationat ISL facilities to a secondary class of use standard for selectconstituents that did not meet the primary restoration target (areturn to baseline levels).3. Placement of a permanent radon barrier [§192.32(a)(3)]:Not applicable to an ISL facility - there are no tailings. All otherbyproduct materials have been or will be removed and transportedto the Shirley Basin Mine tailings site or other licensed facility fordisposal.4. Monitoring of radon releases through the permanent radonbarrier [§192.32(a)(4)]: Not applicable.5. Management of uranium byproduct materials in conformancewith Part 190 and Part 440 of 40 CFR Chapter 1[§192.32(a)(5)]:Included with this submittal as pdf files copied to a CD are thedose to the public evaluationsdone prior to the latest suspension ofoperations. Such evaluationswere not continued during theclosure period. Liquid effluent discharges relating to the ISLoperations were conducted under a NPDES permit issued by theWDEQ. A copy ofthe last NPDES permit and representativedischarge reports submitted under the permit are included as pdffiles on a CD.

COGEMA Mining, Inc., Christensen Ranch Satellite Facility:1. Ponds construction [§ 192.32(a)(1)]: All ponds at thesite were constructed consistent with the approved mine permitupdate to WDEQ and the NRC license update (same document-see pdffiles on the CD).2. Conformanceto the ground water protection standard[§192.32(a)(2)]: Included with this submittal as pdffiles copied toa CD are NRC Source Material License SUA-1341 whichestablishes operational conditions regarding ground waterprotection and the wellfield restoration report dated March 5, 2008which has been submitted to both the WDEQ and the NRC. Thatdocument is currently under review by both agencies.

4

COGEMA Mining, Inc. & Pathfmder Mines Corp. Appendix B Response to EPA Inquiry Dated September2,2008. SubmittedNovember 14,2008.

3. Placement of a pennanent radon barrier [§192.32(a)(3)]:Not applicable to an ISL facility - there are no tailings. All otherbyproduct materials have been or will be removed and transportedto the Shirley Basin Mine tailings site or other licensed facility fordisposal.4. Monitoring of radon releases through the pennanent radonbarrier [§192.32(a)(4)]: Not applicable.5. Management of uranium byproduct materials in confonnancewith Part 190 and Part 440 of 40 CFR Chapter 1[§192.32(a)(5)]:Included with this submittal as pdf files copied to a CD are thedose to the public evaluations done prior to the latest suspension ofoperations. Such evaluations were not continued during theclosure period. Liquid effluent discharges relating to the ISLoperations were conducted under a NPDES pennit issued by theWDEQ. A copy of the last NPDES pennit and representativedischarge reports submitted under the pennit are included as pdffiles on the CD.

COGEMA Mining, Inc., Holiday-El Mesquite Facility:1. Ponds construction [§ 192.32(a)(1)]: All ponds at thesite pre-date the effective date (December 6, 1983) of 40 CFR §192.32(a).2. Confonnance to the ground water protection standard[§192.32(a)(2)]: Included with this submittal as pdffiles copied toa CD are the Texas Radioactive Materials License L03024 whichestablishes operational conditions regarding ground waterprotection and the various wellfield restoration authorizations(approvals) issued by the State of Texas.3. Placement of a pennanent radon barrier [§192.32(a)(3)]:Notapplicableto an ISLfacility- there are no tailings. All otherbyproduct materials have been or will be removed and transportedto the Shirley Basin Mine tailings site or other licensed facility fordisposal.4. Monitoring of radon releases through the pennanent radonbarrier [§192.32(a)(4)]: Not applicable.5. Management of uranium byproduct materials in confonnancewith Part 190 and Part 440 of 40 CFR Chapter 1[§192.32(a)(5)]:Included with this submittal as pdf files copied to a CD are recentdose to the public evaluations. The enclosed reports reference theTexas Administrative Code at 25 TAC 289.202. Due to areorganization of the code, the current reference is 30 TAC§336.313 which in turn references 40 CFR Part 190. Liquideffluent discharges relating to the ISL operations did not occur atthis site.

5

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COGEMA Mining, Inc. & Pathfmder Mines Corp. Appendix B Response to EPA Inquiry Dated September2,2008. Submitted November 14,2008.

COGEMA Mining, Inc., O'Hem Facility:1. Ponds construction [§ 192.32(a)(1)]: The pond atthesite pre-dated the effective date (December 6, 1983) of 40 CFR §192.32(a).2. Conformance to the ground water protection standard[§192.32(a)(2)]: Included with this submittal as pdffiles copied toa CD are the Texas RadioactiveMaterials License L03024 whichestablishes operational conditions regarding ground waterprotection and the various wellfield restoration authorizations(approvals) issued by the State of Texas.3. Placement of a permanent radon barrier [§I92.32(a)(3)]:Notapplicableto an ISLfacility- thereareno tailings. All otherbyproduct materials have been or will be removed and transportedto the Shirley Basin Mine tailings site for disposal.4. Monitoring of radon releases through the permanent radonbarrier [§192.32(a)(4)]: Not applicable.5. Management of uranium byproduct materials in conformancewith Part 190 and Part 440 of 40 CFR Chapter I [§192.32(a)(5)]:See discussion above for Holiday-EI Mesquite regarding dose tothe public evaluations; such evaluationswere not done specific tothis satellite facility since the main processing facility was atHoliday-EI Mesquite. Liquid effluent discharges relating to theISL operations were not conducted at this site.

COGEMA Mining, Inc., West Cole Facility:1. Ponds construction [§ 192.32(a)(1)]: The ponds at thesite pre-dated the effective date (December 6, 1983)of 40 CFR §192.32(a).2. Conformance to the ground water protection standard[§192.32(a)(2)]: Includedwith this submittal as pdffiles copied toa CD are the Texas Radioactive Materials License L03024 whichestablishes operational conditions regarding ground waterprotection and the final completion review report (approval) issuedby the State of Texas, and the concurrence letter from the NRC.3. Placement of a permanent radon barrier [§192.32(a)(3)]:Not applicableto an ISLfacility- there are no tailings. All otherbyproduct materials have been or will be removed and transportedto the Shirley Basin Mine tailings site for disposal.4. Monitoring of radon releases through the permanent radonbarrier [§192.32(a)(4)]: Not applicable.5. Management of uranium byproduct materials in conformancewith Part 190and Part 440 of 40 CFR Chapter 1[§192.32(a)(5)]:See discussion above for Holiday-EIMesquite regarding dose tothe public evaluations; such evaluationswere not done specifictothis satellite facility since the main processing facility was at

6

COGEMA Mining, Inc. & Pathfmder Mines Corp. Appendix B Response to EPA Inquiry Dated September2,2008. Submitted November 14,2008.

Holiday-EIMesquite. Liquid effluent discharges relating to theISL operationswere not conducted at this site.

g) Constructionpennit applications or pennits issued pursuant to 40 CFR §§61.07 and 61.08 or any state authority:

Conventional Uranium Mill and Tailings Facilities -Pathfmder Mines Corporation, Lucky Mc Mine:Air quality pennits for this site were limited to the pennit issued byWDEQ for the operation of the mill facility. That pennit, MD-28,was issued in June, 1979. It is no longer in effect due to sitereclamation. See the enclosed pdffile of the pennit. No otherspecific air quality pennits applied to any of the tailings ponds.There was one construction permit issued by WDEQ/WaterQuality Division for the construction of an enlargementto the No.4 tailings embankment, the furthest downgradient structure in thetailings system. None of the other ponds were permitted forconstruction, primarily due to their vintage.

Pathfinder Mines Corporation, Shirley Basin Mine:No pastair qualitypennitor pondconstruction .

applications/pennits could be located in the company files.site closure such records may have been lost.

Due to

In-situ Leaching Facilities -. COGEMAMining,Inc.lrigarayMine:There is an air quality pennit issued by the WDEQ for theoperation of a yellowcake (uranium concentrate) dryer. See theenclosed pdffile of the pennit. No other specific air qualitypermits applied to any of the ponds. A search of existing filesproduced infonnation from three sources relating to theconstruction pennitting ofthe ponds at Irigaray. The ponds arepresented as part of the mine pennit application and NRC licenserenewal; they are covered by Pennits to Construct issued by theWDEQ/Water QualityDivision; and they are pennitted through theWyoming State Engineer (see enclosed pdf file regarding Irigaraypond constructionpermits/applications). Note that the 517pondsreferenced in the renewal document were small lined structuresutilized in a pilot (feasibility) operation prior to the pennitting offull scale operations. Those ponds have been removed (includingremoval of all radiologicallycontaminated material) and the sitereclaimed.

COGEMA Mining, Inc. Christensen Ranch Satellite Facility:Since this is a satellite facility to the Irigaray Mine, there is noseparate air quality pennit issued in conjunction with the site.

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COGEMA Mining, Inc. & Pathfmder Mines Corp. Appendix B Response to EPA Inquiry Dated September2,2008. SubmittedNovember 14,2008.

See the pdf file for the Wyoming constructionpemits for thevarious ponds.

COGEMA Mining, Inc. Holiday-EIMesquite Facility:Air quality operating permit issued by the Texas Air Control Boardfor the central plant, primarily relating to the operation of theyellowcake dryer and packaging facilities, and a hot oil heater. Allsuch facilities have been decommissioned,and the air qualitypermit is no longer in effect. See the enclosedpdf file of thepermit. No other specific air quality permits applied to any of theponds. Only one pond construction permit application could belocated in company files (see the enclosed pdf file).

COGEMA Mining, Inc. O'Hem Facility: No air quality permitcould be located in company files for this facility. No pondconstruction application or permit to construct could be found incompany files.

COGEMA Mining, Inc. West Cole Facility: No air quality permitlocated for this facility. Apparently there was an original permitrelating to the site, but it could not be found in accessible files.Note that this facility has been permanently closed,decommissioned, and released to unrestricted use. No separatepond construction permit or application to construct was found incompany files.

h) Other permits under the Clean Air Act:Conventional Uranium Mill and Tailings Facilities -Pathfinder Mines Corporation, Lucky Mc Mine and Shirley BasinMine: none.

In-situ Leaching Facilities -COGEMA Mining, Inc., Irigaray Mine and ChristensenRanchSatellite Facility: none.COGEMA Mining, Inc. Holiday-EIMesquite, O'Hem, and WestCole Facilities: none.

i) Copies of licenses or license applications issued by or filed with theNuclear Regulatory Commission (NRC):

Conventional Uranium Mill and TailingsFacilities -Pathfinder Mines Corporation,Lucky Mc Mine: See enclosed pdffile of current license issued by the NRC. Note that this site hasbeen closed and is awaiting permanent transfer to the U.S.Department of Energy. There are no license applications forconstruction or operation outstanding.

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COGEMA Mining, Inc. & Pathfmder Mines Corp. Appendix B Response to EPA Inquiry Dated September2,2008. Submitted November 14,2008.

Pathfinder Mines Corporation, Shirley Basin Mine: See enclosedpdffile of current license issued by the NRC. Note that this sitehas been, for the most part, closed. The only ongoing activity isthe licensed disposal of II.e.(2) material from select ISLoperations in the No.3 pond area. There are no licenseapplications for construction or operation outstanding.

In-situ Leaching Facilities -COGEMA Mining, Inc. Irigaray Mine and Christensen RanchSatellite Facility: See enclosed pdffile ofthe current licenseissued by the NRC. A license renewal application for the projectwas submitted to the NRC on May 31, 2008. See enclosed pdf fileof the renewal application.

COGEMA Mining, Inc. Holiday-EIMesquite, O'Hem, and WestCole Facilities: See enclosedpdffile of the current license issuedby the State of Texas. There are no license applications forconstruction or operation outstanding since all of these sites are inclosure.

j) Copies of any other licenses issued by states under state authority:Conventional Uranium Mill and Tailings Facilities -Pathfinder Mines Corporation, Lucky Mc Mine and Shirley BasinMine: none.

In-situ Leaching Facilities -COGEMA Mining, Inc. Irigaray Mine and Christensen RanchSatellite Facility: See enclosed pdf file of mine permit issued bythe WDEQ. The mine permit covers aspects of processing plant,including evaporation ponds.

COGEMA Mining, Inc. Holiday-EIMesquite, O'Hem, and WestCole Facilities: none.

k) Current license status:Conventional Uranium Mill and Tailings Facilities -Pathfinder Mines Corporation,Lucky Mc Mine: License is in adecommissioning/closurestatus. Site closure completed; awaitingsite transfer to DOE and termination ofPathtinder's license.

Pathfinder Mines Corporation, Shirley Basin Mine: License is in adecommissioning/closurestatus with proviso for continuation ofII.e.(2) material disposal at the site. Balance of tailings areaclosure has been completed.

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COGEMA Mining, Inc. & Pathfmder Mines Corp. Appendix B Response to EPA Inquiry Dated September2,2008. Submitted November 14,2008.

In-situ Leaching Facilities -COGEMA Mining, Inc. Irigaray Mine and ChristensenRanchSatellite Facility: The license was recently amendedby the NRCfrom a decommissioningstatus to operational (as yet operationshave not started). The NRC considers the license to be under"timely renewal", based on the submittal of the renewal applicationfor continuing operations submitted on May 31, 2008.

COGEMA Mining, Inc. Holiday-El Mesquite, O'Hem, and WestCole Facilities: The Holiday-El Mesquite and O'Hem sites arecovered by the same Texas radioactive materials license. BecauseTexas is an agreement state, the Texas Commission onEnvironmental Quality is the administrator/licensorof the currentlicense. That license, while technically expired, has continued as afunctional regulatory device. Renewal of the license has beenpostponed in anticipationof the near term completion ofdecommissioning,and final sites closure. The West Cole facilitypreviously was coveredby a separate license, but was subsequentlymerged into the existing license (L03024). The site has beendecommissioned, released for unrestricted use, and the licenseterminated.

1) Construction and operation of facilities and ponds in accordancewith allpermits and federal regulations:

ConventionalUraniumMillandTailingsFacilities-Pathfinder Mines Corporation,Lucky Mc Mine: To the best ofPathfinder Mines Corporation's knowledge, the construction of thetailings ponds and facilities was done in accordancewith thepermits and federal regulations in effect at the times ofconstruction. Due to the completion of site decommissioning,there are no current operations.

Pathfinder Mines Corporation, Shirley Basin Mine: To the best ofPathfinder Mines Corporation's knowledge, the construction of thetailings ponds and facilities was done in accordance with thepermits and federal regulations in effect at the times ofconstruction. Due to the completion of most sitedecommissioning,there are no current operations. However, anintermittent activity is the disposal of 11.e.(2)wastes from certainISL licensees in the No.3 pond area; that activity, to the best ofPathfinder Mines Corporationsknowledge, is being conducted inaccordance with all permits and federal regulations.

In-situ LeachingFacilities -COGEMA Mining, Inc. Irigaray Mine and ChristensenRanchSatellite Facility: To the best of COGEMA Mining, Inc.'s

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COGEMA Mining, Inc. & Pathfmder Mines Corp. Appendix B Response to EPA Inquiry Dated September2,2008. SubmittedNovember 14,2008.

knowledge, the construction of the evaporation/holdingponds ~dfacilities was done in accordance with the permits and federalregulations in effect at the times of construction. The ponds andfacilities are being operated in accordance with all permits andfederal regulations, to the best of COGEMAMining, Inc.' sknowledge.

COGEMA Mining, Inc. Holiday-EI Mesquite, O'Hem, and WestCole Facilities: To the best of COGEMAMining, Inc.'sknowledge, the construction of the evaporation/holdingponds andfacilities was done in accordance with the permits and federalregulations in effect at the times of construction. Most of thefacilities and ponds at these sites have been decommissioned.Remaining facilities and ponds are being operated in accordancewith all permits and federal regulations, to the best of COGEMAMining, Inc.' s knowledge.

m) Description of any pollution control equipment:Conventional Uranium Mill and TailingsFacilities-Pathfinder Mines Corporation, Lucky Mc Mine: Due to thecompletion of site decommissioning,there is no pollution controlequipment on site.

Pathfinder Mines Corporation, Shirley Basin Mine: All of thesolid tailings ponds have been covered, including placement of thefinal radon barrier. The II.e.(2) burial process involves using oneopen trench at a time for material placement with periodic earthencovering ofthe waste. The rest of the No.3 pond basin has aninterim earthen cover in place. There is no other pollution controlequipment on site.

In-situ Leaching Facilities -COGEMA Mining, Inc. Irigaray Mine and ChristensenRanchSatellite Facility: Pollution control equipment includes a scrubberon the uranium concentrate (yellowcake) dryer with a 95% to 99%efficiency for the removal of uranium particulates, a dust collectionbaghouse for the dried product packaging process, and themaintenance of a partial vacuum in the dryer enclosure to containparticulates. The operating permit from WDEQ specifiesoperating limits for scrubberpressure, scrubber liquid flow rate,and stack emissions. Other equipment consists of enclosed tanksto limit radon and other releases, curbed containment basinsaround tanks with retrieval sumps to control spills, alarm systemsto detect pipeline pressure drops, indicative of a possible leak, andthe routine maintenance of sufficientpond liquid levels to cover

11

COGEMA Mining, Inc. & Pathfmder Mines Corp. Appendix B Response to EPA Inquiry Dated September2,2008. Submitted November 14,2008.

bottom sediments in holding/evaporationponds. Two permitteddeep disposal wells are available for the disposal of process wastewater.

COGEMA Mining, Inc. Holiday-EIMesquite, O'Hern, and WestCole Facilities: All processing plant facilities have beendecommissioned, and there is no plant-related pollution controlequipment left at the sites. There are two above ground storagetanks used in support of injection into a permitted deep disposalwell at the Holiday-El Mesquite site. The Holiday-EI Mesquitesite is the only one where any of the holding/evaporationponds arestill present, and they have been cleaned out and only hold minoramounts of water from rainfall.

n) Statement concerning applicability ofNESHAP for radon emissions asdefined under 40 CFR §§ 61.250 et. seq. (Subpart W):

ConventionalUraniumMillandTailingsFacilities-Pathfinder Mines Corporation, Lucky Mc Mine: The radon-222emission standard of 20 pCi/(m2-sec)is applicable to the site. Therequired annual testing of radon flux was conducted at the site untilthe site went into final closure. Subsequentto completion of thefinal radon barrier over the tailings ponds, a final radon flux testwas conducted, demonstratingcompliancewith the radon emissionstandard. The site was not subject to the work practices due to theearly construction and use of the ponds.

Pathfinder Mines Corporation, Shirley Basin Mine: The radon-222emission standard of 20 pCi/(m2-sec)is applicable to the site. Therequired annual testing of radon flux was conducted at the site untilthe site went into final closure. Subsequent to completion of thefinal radon barrier over the solid tailings ponds, a final radon fluxtest was conducted, demonstratingcompliance with the radonemission standard. The site was not subject to the work practicesdue to the early construction and use of the ponds.

In-situ Leaching Facilities -COGEMA Mining, Inc. Irigaray Mine and Christensen RanchSatellite Facility: The facilities are not subject to the NESHAP forradon emission under Subpart W since there are no tailings. Whilethere are solution ponds that contain sediments,water levels aremaintained over those sediments.

COGEMA Mining, Inc. Holiday-EIMesquite, O'Hern, and WestCole Facilities: The facilities are not subject to the NESHAP forradon emission under Subpart W since there are no tailings. Any

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COGEMA Mining, Inc. & Pathfmder Mines Corp. Appendix B Response to EPA Inquiry Dated September2,2008. SubmittedNovember 14,2008.

ponds structures left (Holiday-EIMesquite only) have beencleaned out and are no longer in use.

Infonnation provided by: T. Hardgrove,R. Owens, L. Arbogast, D.Benevides

5. Results of all air and radon emission tests under 40 CFR §§ 61.253 and 61.255:ConventionalUraniumMillandTailingsFacilities-Pathfinder Mines Corporation,Lucky Mc Mine: See the enclosed radon fluxtest reports to EPA Region 8 along with supporting infonnation, all in pdffonnat. The tests were conducted as specified in 40 CFR §§ 61.253 and61.255. Also see the results and data for the radon flux test conducted on thefmal radon barrier as referenced earlier in this submittal. Also included arepdf files of emission reports to EPA under 40 CFR 61 Subpart 1.

Pathfinder Mines Corporation, Shirley Basin Mine: : See the enclosed radonflux test reports to EPA Region 8 along with supporting infonnation, all in pdffonnat. The tests were conducted as specified in 40 CFR §§ 61.253 and61.255. Also see the results and data for the radon flux test conducted on thefinal radon barrier as referenced earlier in this submittal.

In-situ Leaching Facilities -COGEMA Mining, Inc. Irigaray Mine and ChristensenRanch SatelliteFacility: No radon flux tests were conducted for the reason stated in 4. n)above: there are no tailings on site.

COGEMA Mining, Inc. Holiday-EIMesquite, O'Hem, and West ColeFacilities: No radon flux tests were conducted for the reason stated in 4. n)above: there are no tailings on site.

Infonnation provided by: T. Hardgrove

6. Provide copies of reports as specified in 40 CFR § 61.254:ConventionalUraniumMillandTailingsFacilities-Pathfinder Mines Corporation,Lucky Mc Mine and Shirley Basin Mine: Noreports were generated pursuant to 40 CFR § 61.254 since either the sites werein compliance with the radon emission standard or were in final closure.

In-situ Leaching Facilities - Not applicable.

Infonnation provided by: T. Hardgrove

13

COGEMA Mining, Inc. & Pathfmder Mines Corp. Appendix B Responses to EPA Inquiry Dated September 2,2008. Submitted November 14,2008.

Guide Relating Narrative to pdfFiles on CD

Narrative Section Document CD file

4.c) Lucky Mc Tailings Reclamation Completion Report... ..LuckyMcTailingsReclamationCompletionRptVOL-LpdfLuckyMc TailingsReclamationCompletionRptVOL-II.pdf

Lucky Mc Mill Site Completion Report. . . . . . .LuckyMc- Mill_Site_Completion_Report.pdfShirley Basin Tailings Reclamation Plan ..ShirleyBasinTailingsReclamationPlan.pdf

Shirley Basin Mill Site Completion ReportFor Reclamation of Off-Pile Windblown

Area .XSBM-WindblownTailingsCleanupReport.pdf4.f) Lucky Mc .NRC Source Material License SUA-672 .XSML_SUA-672.pdf

Lucky Mc Application for ACLs .LuckyMcACLApplication.pdfNRC Staff Environmental Assessment

Of Lucky Mc ACLs Application .XLuckyMc_ACLEA.pdfTailings Reclamation Plan. . . . . . . . . . . . . . . .. . . .. .Lucky Mc Tailings Reclamation Plan Voll.pdf

Lucky Mc Tailings Reclamation Plan V012.pdf.Lucky Mc Tailings Reclamation Plan Addendum Lpdf

NRC License Approval of TRP. . . . . . . . . . . . . . . .XLuckyMc_Tailingsy-eclamation]lan - NRC- Approvals.pdfXNRC approval 1MTailings Reclamation Plan Addend. Lpdf

NRC Staff Environmental Assessment &

TechnicalEvaluationfor the TRP .....XLuckyMc_Tailings_Reclamation]lan - NRC- Approvals.pdfXNRCapprovallMTailingsReclamationPlanAddend.Lpdf

Tailings Reclamation Completion Report. . ... LuckyMc TailingsReclamationCompletionRptVOL-LpdfLuckyMcTailingsReclamationCompletionRpt VOL-II.pdf

NRCApprovalof TR CompletionReport.. ...XNRC- Approval- LM-Tailings_Reclamation- Completion-Rpt.pdfLucky Mc Dose to Public Evaluations ...XLuckyMc-40-CFR-190_Dose_to]ublic.pdf

Shirley Basin... NRC Source Material License SUA-442 .XShirley_Basin_Source_Material_License_SUA-442.pdfShirley Basin Application for ACLs ..ShirleyBasinACLApplication.pdfNRC Staff Technical Evaluation for

Shirley Basin ACLs .XShirleYJ3asin_NRC-Lic-Amendmentjor_ACLs-TER.pdfTailings Reclamation Plan ShirleyBasinTailingsReclamationPlan.pdf

COGEMA Mining, . COGEMA Mining, Inc. & Pathfmder Mines Corp. Appendix B Responses to EPA Inquiry Dated September 2,2008. Submitted November 14,2008.

Guide Relating Narrative to pdfFiles on CD

Narrative SectiorHoliday-El Mesquite.

Narrative Section Document CD file

O'Hem.......

NRC License Approval of TRP . . . . . . . . . . . . . . .. SBM TRP Approval.pdf

XShirley_Basin- SUA-442_Amend.Approving-TRP_(with-TER).pdfNRC Staff Technical Evaluation for the TRP SBMTRPApproval.pdf

XShirley ~asin - SUA -442 _Amend. Approving- TRP _(with- TER).pdf

Final Radon Barrier Flux Test Summary ShirleyBasinFinalRadonBarrierFluxTests.pdfLaboratory Rn Flux Data. . . . . . . . . . . . . . . . . . . . . . .. Shirley Basin Final Radon Barrier Flux Tests.pdf

Map of Rn Flux Sampling Grid for FinalRadon Barrier ...S.B. FinalRadon Flux Test Sample Locations-MAP.pdfShirley Basin Dose to Public Evaluations. . ....xShirley _Basin_Dose - to_Public _Eval_in - Lic.Renewal- EA.pdf

Irigaray NRC Source Material License SUA-1341 September30,2008NRCLicenseAmendmentApproval.pdfWellfield Restoration Report ... Irigaray-Wellfield_Restorationy-pt.pdfWellfieldRestorationApprovalby WDEQ... 2004-Irigaray_groundwaterJestoration-WDEQ-Approval.pdfWell field Restoration Approval by NRC 2004_irigaray~roundwater_restoration_NRC_Approval.pdfIrigaray Dose to Public Evaluations XIrigaray_MineJ)ose_to]ublic.pdfIrigaray NPDES Permit ...IR NPDESPERMIT.pdf

IR NPDESPERMIT-l.pdf

West Cole...

4.g) Lucky Mc...

Irigaray .

ChristensenRanch .Holiday-El Mesquite. Irigaray Representative NPDES Discharge

Reports. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Irigaray and Christensen NPDES.pdfXIrigaray Christensen Ranch NPDES-2.pdf4.i) Lucky Mc..,

Shirley BasilIrigaray-ChristensenRanch........

Christensen

Ranch .Mine Permit & License Update (1996) XCurrent]emit_To_Mine-478.pdfNRC Source Material License SUA-1341 September30,2008 NRCLicenseAmendmentApproval.pdfWell field Restoration Report CR-2008-Wellfield_Restoration_Rpt.pdfChristensen Ranch Dose to Public Evaluations XChristensen_Ranch_Dose_to]ub1ic.pdfChristensen Ranch NPDES Permit IrigarayandChristensenNPDES.pdfChristensen Ranch Representative NPDESDischarge Reports Irigarayand ChristensenNPDES.pdf

XIrigarayChristensenRanchNPDES-2.pdf

Texas ISL...4.j) Wyoming IS:5. Lucky Mc...